Privacy Policy & Compliance Disclosures

1. Introduction & Data Controller

T.J. Ogden Co., Inc. (operating as "Ogden Wells", "we," "us," or "our") respects your privacy and is committed to safeguarding the personal information of our website visitors, customers, contractor partners, and dispatch callers.

This Privacy Policy describes how we collect, use, process, disclose, and protect personal data across our website ogdenwells.net, our mobile web applications, customer and technician portals, emergency dispatch forms, and offline service interactions.

Data Controller Identity:
T.J. Ogden Co., Inc.
17 Catherwood Rd., Tewksbury, MA 01876
Toll-Free: 1-800-339-9051 | Office Direct: 978-453-8200
Privacy Officer Email: privacy@ogdenwells.net

2. Information We Collect

We collect personal information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

A. Information You Voluntarily Provide

• Contact & Identity Data: Name, phone number, physical property address, email address, and billing address provided via contact forms, estimate requests, or phone calls.
• Groundwater & Property Specifics: Well depth, casing diameter, static water level, pump horsepower, filter equipment model numbers, water test results, and site access details.
• Emergency Dispatch Details: Emergency triage descriptions, water loss severity, electrical breaker status, and on-site access authorizations.
• Customer & Tech Portal Credentials: Username, securely hashed passwords, and session tokens if you access authorized contractor or administrative portals.

B. Information Collected Automatically

• Device & Telemetry Data: Browser type and version, device category, screen resolution, operating system, and language settings.
• Usage & Interaction Data: Pages viewed, time spent per technical guide, referring URLs, and button interactions.
• Network Identifiers: Truncated/anonymized IP addresses collected through our self-hosted Matomo analytics instance. Ogden Wells masks IP addresses by default to ensure individual visitors cannot be identified directly.

3. Cookies, Tracking & Global Privacy Control (GPC)

We use cookies and similar browser storage technologies to provide core site features, enhance accessibility, and compile anonymous website usage metrics.

• Strictly Necessary Cookies: Required for site navigation, cryptographic session security, emergency service routing, and remembering your cookie consent selections.
• Functional Cookies: Store preferences such as localized service area filters and diagnostic calculator progress.
• Analytics Cookies (First-Party): Self-hosted Matomo analytics with IP masking. We do not send your browsing data to Google, Meta, or third-party behavioral advertising brokers.

Global Privacy Control (GPC) & Do Not Track: We recognize and honor browser-level opt-out preference signals, including Global Privacy Control (GPC). If your browser transmits a GPC signal, our system automatically treats this as a valid request to opt out of any non-essential analytics or marketing cookies.

4. Legal Bases for Processing (GDPR / UK GDPR)

For individuals located within the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data in accordance with Regulation (EU) 2016/679 ("GDPR") under the following legal bases:

• Performance of a Contract (Art. 6(1)(b)): To provide well drilling, pump installation, emergency dispatch, water testing, and warranty servicing requested by you.
• Legitimate Interests (Art. 6(1)(f)): To maintain website security, prevent fraud, improve technical performance, and maintain commercial business records.
• Consent (Art. 6(1)(a)): For non-essential analytics cookies and voluntary customer feedback surveys. You may withdraw your consent at any time via the Cookie Settings trigger in our footer.
• Compliance with Legal Obligations (Art. 6(1)(c)): To satisfy statutory building codes, well completion reporting to state environmental protection departments (e.g., MassDEP, NHDES, RIDEM), and accounting requirements.

5. Your Rights Under GDPR & International Law

Under Chapter III of the GDPR, European and UK residents have the following enforceable rights:

• Right of Access (Art. 15): Request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete records.
• Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your personal data, subject to statutory well completion record retention laws.
• Right to Restriction of Processing (Art. 18): Restrict how your data is processed under specific circumstances.
• Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object (Art. 21): Object at any time to processing based on legitimate interests.
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your national Data Protection Authority (DPA).

6. California Consumer Privacy Rights (CCPA / CPRA)

This section supplements the information above and applies solely to residents of California pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA/CPRA", Cal. Civ. Code § 1798.100 et seq.).

A. Notice at Collection — Categories of Personal Information

B. Statutory Declaration: No Sale or Sharing of Personal Information

Statement of Compliance: Ogden Wells does not sell personal information for monetary consideration, nor do we "share" personal information with third parties for cross-context behavioral advertising as defined under Cal. Civ. Code § 1798.140. We have not sold or shared any consumer personal information in the preceding 12 months.

C. California Consumer Statutory Rights

• Right to Know & Access: Request details regarding categories of personal information collected, sources, business purposes, and specific pieces of data held.
• Right to Delete: Request deletion of personal information, subject to statutory exemptions (e.g., fulfilling drilling contracts, municipal safety records, tax compliance).
• Right to Correct: Request correction of inaccurate personal information.
• Right to Limit Use of Sensitive Personal Information: We only collect sensitive info (e.g., account logins for the portal) strictly necessary to perform authorized portal services.
• Right to Non-Discrimination: We will never deny services, charge different rates, or provide a lower quality of service because you exercised your CCPA/CPRA rights (Cal. Civ. Code § 1798.125).

D. Submitting a Verifiable Consumer Request

To exercise your California rights, you or your authorized agent may submit a verifiable request via:

• Toll-Free Phone: 1-800-339-9051
• Email: privacy@ogdenwells.net
• Interactive Opt-Out: Click Do Not Sell or Share My Info

We will confirm receipt within 10 business days and provide a substantive response within 45 calendar days.

7. Consumer Rights Under the Connecticut Data Privacy Act (CTDPA)

Pursuant to the Connecticut Data Privacy Act (CTDPA, Conn. Gen. Stat. § 42-515 et seq.), residents of Connecticut have specific enforceable statutory rights regarding their personal data:

• Right to Confirm & Access: Confirm whether we are processing your personal data and obtain access to such data.
• Right to Correct: Correct inaccuracies in your personal data, considering the nature and purposes of the processing.
• Right to Delete: Request deletion of personal data provided by or obtained about you, subject to statutory well logging and commercial retention exemptions.
• Right to Data Portability: Obtain a copy of your personal data in a portable and readily usable format that allows you to transmit it to another entity.
• Right to Opt-Out: Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or automated profiling in furtherance of solely automated decisions producing legal or similarly significant effects.
• Right to Non-Discrimination: We will never discriminate against you, deny well drilling or pump services, or charge differing rates for exercising any statutory right.

Statutory Right of Appeal (CTDPA § 42-519): If we decline to take action regarding your consumer request, we will notify you within forty-five (45) calendar days of receipt, providing the justification for our decision. You have the right to appeal our decision within thirty (30) days by submitting an appeal to privacy@ogdenwells.net. We will respond to your appeal in writing within forty-five (45) days. If your appeal is denied, you may contact the Office of the Connecticut Attorney General (portal.ct.gov/ag) or call (860) 808-5318 to submit a consumer complaint.

Other US State Privacy Statutes

We extend equivalent rights of access, correction, deletion, and opt-out to residents of Colorado (CPA), Virginia (VCDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana, New Hampshire, and other jurisdictions with comprehensive consumer privacy statutes. Requests may be submitted through the verified channels below.

8. Massachusetts Data Security Compliance (201 CMR 17.00)

As a Massachusetts corporation headquartered in Tewksbury, MA, T.J. Ogden Co., Inc. strictly complies with201 CMR 17.00: Standards for the Protection of Personal Information of Residents of the Commonwealth. We maintain a comprehensive Written Information Security Program (WISP) that enforces:

• Mandatory TLS 1.3 cryptographic encryption for all web communications and data transmissions across public networks.
• Strict role-based access control policies restricting customer records to authorized administrative and dispatch staff.
• Continually updated operating system patches, malware protection, and multi-factor authentication for administrative consoles.
• Immediate incident assessment protocols to prevent unauthorized access or disclosure of sensitive identifiers.

9. Telecommunications Compliance (TCPA & SMS)

When you provide your phone number through our emergency dispatch modal, customer portal, or estimate forms, we use your number strictly for dispatch coordination, technician arrival notifications, and project updates. We do not send unsolicited marketing robocalls or text messages. You may reply STOP to any SMS update at any time to cancel text notifications.

10. Data Retention & Archival Schedule

We retain personal information only for the period necessary to fulfill the original purposes of collection, enforce contractual warranties, and comply with state environmental and municipal health regulations:

• Estimate & Dispatch Inquiries (Uncompleted): Retained for twelve (12) months to facilitate re-quotes or customer follow-up.
• Active Customer Contracts, Invoices & Warranty Records: Retained for seven (7) years following project completion in compliance with Massachusetts and federal tax accounting standards.
• Master Well Completion Reports & Geological Borehole Logs: Retained for the operational lifetime of the well. Groundwater completion records are critical property assets required for municipal Board of Health filings, MassDEP / NHDES state well databases, pump replacement sizing, and real estate property title transfers.
• Browser Caches & Portal Session Tokens: Managed directly through your browser settings; portal authentication tokens may be purged at any time by clearing your browser cache.

11. Children's Online Privacy (COPPA)

Our website and services are designed for homeowners, builders, commercial property managers, and municipalities. We do not knowingly solicit or collect personal information from children under 16 years of age. If you believe a child has provided us with personal information, please contact us immediately.

11. Changes to This Privacy Policy

We periodically review and update this Privacy Policy to reflect changing legal requirements and operational updates. Any changes will be posted on this page with an updated revision date.

12. Contact Information

If you have questions, comments, or wish to exercise your privacy rights, please contact our Privacy Compliance Department:

T.J. Ogden Co., Inc. / Ogden Wells
Attn: Privacy & Legal Compliance
17 Catherwood Rd., Tewksbury, MA 01876
Toll-Free: 1-800-339-9051
Direct Office: 978-453-8200
Email: privacy@ogdenwells.net